Privacy Policy
Cornerstone Consulting Organization, LLC (“CCO” or “We”) recognizes the importance of protecting personal information. This Privacy Policy describes the types of information that CCO collects from users of the publicly-available portions of the www.ccoconsulting.com internet website and platform (collectively referred to herein as, the “Website”) and how CCO uses and handles such information (including who we might share it with). By accessing or using the Website, you acknowledge that you understand and accept the terms set forth in this Privacy Policy.
Collecting Information
What is “Personal Information”?
“Personal Information” is information about a user of the Website that is personally identifiable to the user, such as the name, address, email address, telephone number and other information specific to the user. Personal Information about a user is provided by the user when they use the Website. We may also collect and process information about a user’s actual location, using the user’s IP address, GPS, and other methods using sensors in nearby equipment, such as Wi-Fi access points and cell towers.
The information described above is referred to in this Privacy Policy as “Personal Information” because it identifies or describes individual or personal aspects about the user.
Children’s Online Privacy Protection Act Notice: We do not knowingly solicit or collect Personal Information from children under the age of 13, nor is the Website or its content marketed or directed to children under the age of 13. In the event that CCO becomes aware that it unknowingly collected Personal Information from a child under the age of 13 without parental consent, CCO will delete that information as quickly as reasonably possible.
What Types of Non-Personal Information Do We Collect?
Other information can be collected from the user’s use and navigation of the Website– such as device-specific information — for example, a user’s hardware type, operating system version, unique device identifiers (UUID or GUID), mobile network information, and server log information (typically, a user’s IP address, browser type, browser language, date and time of request and cookies – discussed separately below).
This type of information is referred to in this Privacy Policy as “Anonymous Information” because it does not identify or describe individual personal aspects about the user, but nevertheless can be collected based on the user’s use of the Website or the code created by a user and stored in the user’s CCO account.
How do We Collect Personal Information of Users of Our Website?
A visitor can access and browse the Website at any time without providing any Personal Information. We collect your Personal Information only from your voluntary submission, such as by submitting questions or comments on the “Contact Us” page, voluntarily electing to receive promotional emails (which will require the submission of certain Personal Information), signing up for a free account, or signing up for a paid subscription. We may also collect your Personal Information (in addition to Anonymous Information connected to your usage) when we review your usage practices or patterns.
When you use our Website, our servers automatically record some of your information that your browser sends whenever you visit a Website, such as your web page request, your IP address, your browser type, your hardware type, the time and date of your visit, any referring websites/URLs, the number of clicks you implemented on the Website, what pages you viewed, and other types of Anonymous Information. This information helps us improve the Website and more accurately provide it to you.
How Do We Use Personal Information Collected?
CCO may use your Personal Information to respond to your email inquiries (when we deem such response to be appropriate); to respond to your submission of a message on our “Contact us” page or other forms or requests which involve your requests for information from us; to send you notices about changes to the Website; to send you notices about services we may offer from time to time (including service-related announcements); if you have given your consent, to send you promotional emails; and to manage and improve the Website to optimize products and services. The legal basis is section 6(1) of the Danish Data Protection Act and art. 6(1)(a) and art. 6(1)(f) of the EU General Data Protection Regulation (GDPR).
We may also use your Personal Information (such as search terms) to optimize exposure and availability on external web search engines such as Google®.
We, like many businesses, sometimes engage other companies (“Service Providers”) to perform certain business-related functions (such as maintaining databases, distributing information, processing transactions, and hosting services). When we engage a Service Provider to provide such business-related functions, we provide them with the information they need to perform such function, and such information may include Personal Information of a user. Service Providers are typically authorized to use such information only as necessary to provide such services to us.
We also may disclose Personal Information in limited situations where necessary to comply with law, administrative or civil process, or to enforce the terms of use of the Website or other legal or equitable rights or entitlements, in our sole discretion.
Google® Analytics. The Website may employ Google® Analytics advertising features that collect data about your traffic via Google® advertising cookies and anonymous identifiers (see “Tracking Cookies/Web Beacons/Social Media Widgets” below) as well as data collected through standard Google® Analytics implementation. We strive to adhere to Google® Analytics Advertising policies. We will not facilitate the merger of personally identifiable information with non-personally identifiable information collected through any Google® advertising product or feature. We reserve the right to test, turn-on or turn-off any of the Google® Analytics features from time to time without notice to you. By utilizing certain Google® Analytics
Advertising Features, we are required to disclose the following information:
In the event that our business is acquired by a third party, all or any party of the data collected by CCO through a user’s use of the Website may be among the assets transferred to the third party in connection with such transaction. The third party would thereafter be entitled to review and use such information (including Personal Information) in connection with its business activities, and in such case, the Privacy Policy of the third party may thereafter apply to such information, rather than this Privacy Policy.
Notice to California Residents: We do not currently maintain a process for individuals who use or visit the Website to review and request changes to any of their personally identifiable information collected through the Website.
Tracking Cookies/Web Beacons/Social Media Widgets
An internet tracking cookie (or HTTP cookie) or web beacon is a small piece of text or code stored on a user’s device by a web browser (such as Internet Explorer®, Apple® Safari®, Google® Chrome®, or Mozilla® Firefox®). Web pages (like those incorporating the Website) use tracking cookies for authentication, session navigation tracking, and storing site preferences. We use tracking cookies to better serve you when you return to the Website.
If you do not want to enable the Website to place tracking cookies on your computer, you can adjust your web browser’s security settings to block tracking cookie placement. You can also adjust your web browser settings to notify you when your computer receives a tracking cookie, which gives you a chance to decide whether or not to accept the tracking cookie before it is placed on your device. If you decide not to accept a tracking cookie from the Website, you may not be able to use all of the features of the Website.
The Website may include social media features, such as “share” widgets through Facebook®, Twitter® or Google+®, “like” buttons through Twitter® and Facebook®, and interactive mini-programs that run on the Website or which populate from third party video sources such as YouTube® and Vimeo®. Such features may collect a user’s IP address, which pages the user visits on the Website, and may set a cookie to enable the feature to function properly. Social media features and widgets may be hosted by a third party or hosted directly on the Website. User’s actions with social media features may be governed by the privacy policy of the provider of the social media features.
Information Security
Storage and Processing. CCO will not store any user’s Personal Information except for the user’s name and email address, provided that such user voluntarily submitted this information to us or agreed to receive promotional emails from us. Your information collected through the Website may be stored and processed in the United States, Europe, or any other country in which CCO or its subsidiaries, affiliates or Service Providers maintain facilities.
Data Transmission. CCO will encrypt your Personal Information prior to transmission to any third party. CCO may transfer information that we collect about you, including Personal Information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or European Economic Area, please note that we will not transfer information, including Personal Information, to a country outside of the European Union or European Economic Area.
Data Retention. We only retain the Personal Information we may collect from you for a limited period of time and as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law.
How We Protect Your Information. CCO is concerned with protecting your privacy and data. We store Personal Information using generally accepted encryption and data-storage technology (such as SSL). However, we cannot guarantee that any information is totally secure. Even though we review such encryption, data storage and data processing practices and security measures from time to time, third parties may unlawfully access, intercept or otherwise become aware of Personal Information or private communications. We do not represent or warrant that the Website is protected from such unlawful interception or other harmful events, such as computer viruses, malware, data mining and security or privacy threats. We are not responsible for intercepted information sent via electronic means, including e-mail or e-commerce transactions. You hereby release us, Service Providers engaged by us, and our respective officers, directors, members, managers, employees, agents and assigns, from any and all claims, costs or expenses arising out of or relating to the use of information intercepted or accessed by third parties in an unauthorized or unlawful manner.
Aggregation Information
We and our Service Providers may collect non-personally identifiable information, or Anonymous Information, about how users of the Website navigate to and through the Website, including the number of visits to the Website and specific pages visited while at the Website and the IP addresses of those visitors to the Website. We may and our Service Providers may aggregate this statistical information and use it to help us administer and to enhance the Website and for research and development, user analysis and business decision-making. These aggregate statistics also may be provided to our marketing affiliates for use in our marketing or advertising activities and/or to assist Service Providers in connection with processing information or maintaining the operation of the Website.
Third Party Site Links
We may provide HTML links to third party websites. We are not affiliated with third parties to whom we provide such links, and we are not responsible for the content, accuracy or privacy practices of the websites to which such HTML links are directed. This Privacy Policy applies only to the Website and not to any third-party web pages or domains operated by third parties. As a general rule, you should always consider checking the privacy policies of third-party websites before submitting Personal Information to such websites.
Governing Law; Individual Nature of Claims
This Privacy Policy is governed by and interpreted pursuant to the laws of the state of Ohio without regard to its conflict of laws principles. If any dispute arises in connection with your use of the Website, the arbitration tribunals and local, state, and federal courts located in the state of Ohio shall have exclusive jurisdiction and venue over such dispute. Visitors or users of the Website who are subject to the jurisdiction of countries other than the United States of America must not submit information of any kind to or through the Website, and waive all liability of CCO, our Service Providers, and our respective directors, managers, officers, employees, affiliates, successors and assigns with respect to submission of such information. ALL USERS OF THE WEBSITE AGREE THAT ANY DISPUTE RESOLUTION PROCEEDINGS WHETHER IN ARBITRATION OR IN COURT WILL BE CONDUCTED ONLY ON AN INDIVIDUAL BASIS AND NOT IN A CLASS, CONSOLIDATED OR REPRESENTATIVE ACTION. Users of the Website further agree that any claim against CCO, our Service Providers, or our affiliates is personal to the user, and any such claim shall only be resolved by an individual arbitration, and shall in no event be brought as a class arbitration, a class action, or any other representative proceeding. The arbitrator may only conduct an individual arbitration, and may not consolidate more than one person’s claims and may not preside over any form of representative or class proceeding.
Changes to this Privacy Policy
We reserve the right to update, amend, or change this Privacy Policy at any time. If we change this Privacy Policy on the Website, we will adjust the “Last Modified” date at the bottom of this Privacy Policy. For this reason, you should check the Privacy Policy each time you use or visit the Website to keep informed of any changes to the Privacy Policy.